New Technologies, New Risks?
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New Technologies, New Risks?

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New financial and communication technologies offer a great opportunity to improve the lives of people everywhere. For instance, millions of impoverished people now have access to the financial system through stored value cards or mobile phones. However, some are concerned that governments are not always aware of these innovations in their jurisdictions. This has prompted fear that fast-moving terrorist groups could expand funding undetected. The fear has led some countries to take a restrictive stance on the technologies' use, either by outright prohibition or by placing unnecessary limitations that deter market development. Authorities are therefore challenged to tackle the double-sided nature of technological advancement: promoting security and economic growth. 'New Technologies, New Risks? Innovation and Countering the Financing of Terrorism' explores how money flows via these mediums, risks they pose, and how governments have mitigated the risks.

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Published 30 November 2009
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EAN13 9780821381779
Language English
W O R L D B A N K W O R K I N G P A P E R N
New Technologies, New Risks? Innovation and Countering the Financing of Terrorism
Andrew Zerzan
THE WORLD BANK
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Innovation and Countering the Financing of Terrorism
New Technologies, New Risks?
Andrew Zerzan                         
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Copyright © 2010 The International Bank for Reconstruction and Development / The World Bank 1818 H Street, N.W. Washington, D.C. 20433, U.S.A. All rights reserved Manufactured in the United States of America First Printing: November 2009 Printed on recycled paper  1 2 3 4 5 12 11 10 09  World Bank Working Papers are published to communicate the results of the Bank’s work to the development community with the least possible delay. The manuscript of this paper therefore has not been prepared in accordance with the procedures appropriate to formallyedited texts. Some sources cited in this paper may be informal documents tha t are not readily available. The findings, interpretations , and conclusions expressed herein are those of the author(s) and do not necessarily reflect the views of the International Ban k for Reconstruction and Development/The World Bank and its affiliated organizations, or thos e of the Executive Directors of The World Bank or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominat ions, and other informa tion shown on any map in this work do not imply any judgment on the part of The World Bank of the legal status of any territory or the endorsement or acceptance of such boundaries. The material in this publicat ion is copyrighted. Copying and/or transmitting portions or all of this work without permission may be a violation of applicable law. The International Bank for Reconstruction and Development/The World Bank encourages dissemination of its work and will normally grant permission promptly to reproduce portions of the work. For permission to photocopy or reprint any part o f this work, please send a request with complete information to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, USA, Tel: 9787508400, Fax: 9787504470, www.copyright.com. All other queries on rights and licenses, includi ng subsidiary rights, should be addressed to the Office of the Publisher, The World Bank, 1818 H St reet NW, Washington, DC 20433, USA, Fax: 202522 2422, email: pubrights@worldbank.org.   ISBN13: 9780821380864 eISBN: 9780821381779 ISSN: 17265878 DOI: 10. 1596/9780821380864  Library of Congress CataloginginP ublication Data has been requested.    
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Foreword ...................................................................................................................... ............... v  Acknowledgments ............................................................................................................... .... vi  Executive Summary ................................................................................................................ vii  Acronyms and Abbreviations ................................................................................................ ix  Author’s Biography............................................................................................................ ....... x  1. Introduction............................................................................................................... ............. 1  Emerging Opportunities and Risks to the Markets........................................................ 1  International Calls on the Issue......................................................................................... 2  Objective. .............................................................................................................................. 2  Layout of the Paper ........................................................................................................... . 2  2. Value Card Systems ......................................................................................................... ..... 4  3. Mobile Phone Financial Services ....................................................................................... 9  Mobile Financial Information .......................................................................................... 10  Mobile Bank and Securities Account.............................................................................. 10  Mobile Payment ................................................................................................................ 10  4. Online Banking and Payment Services ........................................................................... 19  Internet Banking.............................................................................................................. .. 20  Internet Payments ............................................................................................................. 21  5. Digital Currency ........................................................................................................... ....... 26  6. Conclusions ................................................................................................................ .......... 30  References.................................................................................................................... ............. 34    
Contents  
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Tables Table 5.1. Payment Methods and Risks of Abuse ............................................................... 31   Figures Figure 2.1. Centrally Recorded and UnitRecorded Value Card Setup ............................. 6  Figure 3.1. Surge in Mobile Connection s across All Regions .............................................. 9  Figure 3.2. Billions of mFS users in 2007 (actual) and 2015 (estimated) ......................... 16  Figure 4.1. Internet Boom ac ross Regions 1990–2005 (users per thousand people) ....... 19  Figure 4.2. Percent of Chinese and American Internet Users Accessing Online Payment and Banking Services ...................................................................................... 20  Figure 4.3. Transaction Limits for Moneyb ookers.com for UK residents ........................ 23  Figure 4.4. Online Revenue Lost t o Fraud, Proportion of Total Revenue 2000–07 ......... 25  Figure 5.1. Typical Digital Currency Exchange Setup........................................................ 27   Boxes Box 3.1. Riskbased Determination of Transaction Limits ................................................. 14  Box 4.1. Indicators of Internet Payment System Crime ...................................................... 22   
iv  Contents
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Foreword
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T of tools in response, ranging from the political to the economic. In attempting to prevent and detect terrorist financing and other forms of material support, those offering financial services have been required to heighten their vigilance of potential terrorist abuse of those services. While protecting financial services from potential abuse, care should be taken not to deny access to those services to those most in need. Dejection and social exclusion are very often conducive to terrorism; therefore, ensuring inclusion of the disenfranchised and creating possibilities for their advancement is a key part of the broader, longterm struggle against terro rism and extremism. Expanding access to the financial system while promoting market integrity is critical to delivering real opportunities and relieving despair. International standards and best practices on the fight against money laundering and terrorism financing have been developed over the past two decades. A review of the implementation and effectiveness of the standards on terrorism financing has recently been conducted under the aegis of the United Nations, with the World Bank playing a leading role. A recently published report, Tackling the Financing of Terrorism, by the UN CounterTerrorism Im plementation Task Force, made nearly a hundred recommendations on an array of terrorist financing issues, including new technologies, nonprofit organizations, informal remittance providers and international cooperation. This paper addresses one of those recommendations, that the international community should promptly raise awareness of the risks, if any, of new technologies and practices for reducing them. We hope that it will bring useful insight to policy makers and practitioners as they work to protect their markets and communities from these terrorist threats while ensuring that the financial system works to facilitate economic development for the poor.  Consolate Rusagara Director, Financial Systems World Bank
 
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Acknowledgments 
T his paper was created as a result of the World Bank’s participation in the United Nations Counter Terrorism Implementation Task Force. This important brainstorming exercise provided access to many great minds in fields such as police, economics, law, intelligence, banking and finance as well as the workings of the international system. The opportunity to discuss, debate with, and listen to these many individuals made this paper possible. The substantive inputs and guidance by Emile van der Does and Jean Pesme (both from Financial Market Integrity, World Bank) are also especially appreciated. The peer reviewers for this paper are: Dr. Thaer Sabri (EMoney Association), Sarah Rotman (Consultative Group to Assist the Poor), Emmanuel Mathias and Alain VedrenneLacombe (both from the International Monetary Fund), Michael Defeo (United Nations Office on Drugs and Crime), David Murray (United States Treasury), and Carlo Corazza (Payment Systems, World Bank). Their comments and discussions before, during, and after the drafting greatly helped sharpen the paper and enlighten the author about their very diverse fields. Lastly, the author would like to thank the following people and organizations for information provided or advice they shared about their experience in this field. Arvind Gupta, Wameek Noor, and PierreLaurent Chatain (all from the World Bank), Marina Solin (GSMA, a global mobile industry association), the U.S. Federal Reserve Bank of New York, Wayne Laramee (UK Financial Services Authority), Governor Sultan Al Suwaidi (Central Bank of the United Arab Emirates), the EMoney Association, Arabinda Achayra (Nanyang University, Singapore), Sue Eckert (Brown University), Chady ElKhoury (International Monetary Fund), the Monetary Authority of Singapore, Horst Intscher (former director of Canada’s Financial Intelligence Unit), and the U.S. Federal Bureau of Investigation.   
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Executive Summary
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R crimes such as terrorist financing. This paper explores four innovations—value cards, mobile financial services, online banking/pa yments, and digital currencies—outlining how they work, analyzing their risks, and identif ying some ways in which governments and providers are attempting to reduce their attractiveness to financiers of terrorism. Determining what the actual risks are is critical to ensuring that laws and regulations balance both the need to protect integrity in the market and to create an environment friendly to business and empowering to the poor. Value Cards One of the new mechanisms by which people can make a payment via a piece of plastic called a value card. These cards can be broken into two basic technology types: (i) centrally recorded value cards, in which the value of the card is stored in a main database; and (ii) unit value–recorded cards in which the value is kept on the card itself. The difference in the way the value is recorded is key to analysis of the terrorist financing risks and the measures for mitigating them. This is due to the location of the fund/activity records. Whether they are on the card or recorded elsewhere affects the ability of the operator or authorities to monitor account activity for criminal abuse. Unitrecorded cards are declining in use and have a low level of interoperability outside a specified geography that has specialized retailers equipped to read the card. Their attractiveness to financiers of terrorist appears rather low. Centrally recorded value card technology, on the other hand, is growing in many parts of the globe. There is anecdotal evidence—but no known legal cases—that such cards have been used by terrorists to transfer funds because their value cannot be easily determined by customs and border control agents. However, the fact that these cards are centrally recorded has enabled the industry to develop tools that can help prevent their abuse such as activity monitoring systems and geographical limitations. Mobile Financial Services The very rapid and global boom of the mobile phone business has facilitated the expansion of another industry with great potential to enhance economic development, especially among the poor. Mobile financial services include ways to send and store money by using an existing bank account, opening a new account, or even bypassing a bank account altogether. There are some inherent risks that these services carry yet it is the fact that providers are varied and are sometimes not overseen by authorities that may pose the greatest risk of their abuse for criminal purposes. At the same time, it is important to note that research did not find a single case of terrorist financing activity through mobile phone financial services to date. This positive sign is a reminder to policy makers moving forward: the regulation of mobile financial services should be based upon the risk they pose and not fear of the unknown.
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viii  Executive Summary
 
Online Banking and Payments Globally, about a fifth of the world uses the Internet with increasing numbers everywhere. Coinciding with the expansion of Internet usage is the adoption of online banking and payment services such as Internet banking and payments. While online banking goes through a bank account and therefore merely extends existing service, Internet payments do not. The latter are usually facilitated by nonbank financial intermediaries that generally do not make loans or deposits. Internet banking does not seem to present a new or greater risk of being vulnerable to criminal abuse other than fraud, which is being tackled by the industry as fraud directly affects profitability. With this exception in mind, indications are that it presents challenges much the same as more conventional means of banking. On the other hand, online payments may pose a greater challenge because online payment providers sometimes fall outside the regulatory regime. This is often because providers in this industry are usually not banks and the government may not have enough time to catch up with the market. It is also the case that governments are at times unaware of such systems operating in their country. There is no evidence that either of these online financial services is inherently more attractive to terrorist financiers than other channels to transfer value. Digital Currency Distinct from other online banking and Internet payment systems, there exist complex, non governmentbased units of value called digi tal currency—also known as digital precious metal because its value is linked to a valuable commodity such as gold. This currency is exchanged between account holders of the service. The systems exist outside of any one jurisdiction, making single government oversight impossible, and thus are a cause of concern. A recent case supports this apprehension because the largest provider of digital currency was prosecuted and pled guilty to charges that it was complicit in criminal financial abuse of its system, inc luding money laundering. At the same time, there is little reason to believe that digital currencies are attractive to terrorist financiers in particular. The systems have existed for several years and except for a single case (which remains undecided), research has not found any proof of their particular appeal to terrorist supporters. The international nature of digital currency systems demands the supervision of far more than a single national authority. Digital currency is vulnerable to lack of proper oversight. Since they are naturally multijurisdi ctional, governments should look toward developing criteria for determining supervisory responsibility. Conclusion The paper concludes that these new methods of payment do not offer particular usefulness to terrorist financiers. However, some of these channels could be attractive for general criminal abuse  because they have an ambiguous place in the legal regime. Providers therefore, may not know about or elect to properly mitigate risks. The industry is encouraged to work within itself to share information to prevent and detect criminal activity. Governments should consult with industry in deciding regulation and industry should notify government prior to rolling out a new service. This will make government oversight more effective. Lastly, since many of these services are international in scope, government coordination and awareness raising is central.  
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Acronyms and Abbreviations
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antimoney laundering customer due diligence Combating the Financing of Terrorism United Nations Counter Terrorism Implementation Task Force Financial Action Task Force on Money Laundering and Terrorist Financing GSM Association, the global mobile industry organization “know your customer, ” rules for customer identification mobile phone financial services point of sale
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Author’s Biography
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Andrew Zerzan  analyzes technology as a key driver for sustainable economic development. At the World Bank, his work has focused on new innovations and their role in promoting access to financial services and market integrity. In 2006, Mr. Zerzan initiated published research on information and communication technologies for economic development at the World Bank Institute. His analysis has gauged the effectiveness of national and international regimes to mitigate the risks of growth, such as illicit money flows, terrorist financing, and money laundering. In 2008 he co authored firstofitskind research on mobile banking in a report titled Integrity in Mobile Phone Financial Services , which separates the fact from the fiction on its risks. He was also part of the United Nations Cou nter Terrorism Implementation Task Force from 2007–2009, where he drafted and coor dinated the global report called Tackling the Financing of Terrorism. Mr. Zerzan draws on his private sector experience as a consultant in Japan where he built a grassroots business that has bridged disparities in strategic communications among global companies. He was educated in the United Kingdom, Spain, Canada, and the United States. He is currently based in London, and can be reached at andrewzerzan@gmail.com.   
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